Safety & Compliance: What Strict Formulation Standards Must Be Followed to Manufacture Scent Sprays for Public Space Use?

As the "olfactory economy" continues to expand, scented products are increasingly penetrating public spaces—hotels, shopping malls, office buildings, ride-hailing vehicles, and restaurants. Unlike home fragrances used in well-ventilated private spaces, public space scent sprays face a fundamentally different regulatory landscape. They must satisfy application safety (how the product behaves during use), environmental safety (how it affects indoor air quality), and ingredient safety (what chemicals it contains).

At ENO Aroma, we understand that safety is the true entry ticket to public space applications. This article provides a comprehensive overview of the strict formulation standards required for manufacturing scent sprays intended for public spaces, covering VOC limits, harmful substance controls, material restrictions, and emerging regulatory frameworks.

1. Why Public Space Scent Sprays Face Stricter Standards

The distinction between home-use and public-space-use fragrance products is not merely semantic—it is grounded in fundamental differences in exposure patterns.

1.1 The Confined Space and Cumulative Exposure Factor

Unlike private residences where occupants can control ventilation, public spaces such as offices, hotel lobbies, and vehicles operate as enclosed environments with continuous occupancy. Scent sprays used in these settings release fragrance compounds that accumulate in the indoor air over time. Even if each individual chemical meets safety limits, the combined effect of multiple volatiles can result in elevated Total Volatile Organic Compound (TVOC) concentrations that exceed indoor air quality standards.

1.2 The Secondary Pollution Risk

A critical finding from recent research reveals that "natural" is not always safer. Studies conducted during the development of Shanghai’s new fragrance safety standard found that some expensive "100% natural essential oil" products actually posed higher indoor air pollution risks than certain synthetic fragrances.

The scientific explanation lies in the chemical composition of natural essential oils. Natural oils are rich in terpenes such as limonene and pinene. When these compounds volatilize into the air, they readily react with trace ozone present indoors, generating secondary pollutants including formaldehyde and ultrafine particulate matter (secondary organic aerosols). This reaction chemistry means that a product’s safety cannot be judged solely by its ingredient list—it must be evaluated by its actual emissions in use.

1.3 The Regulatory Gap

Historically, fragrance safety standards focused primarily on ingredient safety—limiting specific hazardous substances in the raw materials. For example, China’s GB/T 22731 Fragrance standard restricts 125 chemical substances and prohibits 85 others in fragrance raw materials. However, these standards do not address use-phase emissions, leaving a regulatory gap for products designed to continuously release fragrance into occupied spaces.

This gap is now being addressed by new regulatory frameworks that shift the focus from "ingredient safety" to "space safety."

2. Volatile Organic Compound (VOC) Limits

VOCs are the primary concern for public space scent sprays. Regulatory authorities have established specific VOC content limits by product category.

2.1 U.S. Federal VOC Limits (EPA)

Under the U.S. Environmental Protection Agency’s Consumer Products Rule (40 CFR Part 59 Subpart C), air fresheners are subject to VOC content limits based on product type:

For public space scent sprays, the Liquid/Pump Spray category (18% VOC limit) is most relevant. These limits apply to the product’s VOC content at the time of manufacture and sale.

2.2 State-Level VOC Regulations

Several U.S. states have established stricter VOC limits than federal requirements, often aligned with the Ozone Transport Commission (OTC) Model Rule. California has been particularly influential, recently adding new air freshener categories to its regulations, including manual air freshener and concentrated aerosol air freshener.

Virginia’s VOC regulations specify the following limits for air fresheners under 9VAC5-45-430:

These state-level limits are often more stringent than federal standards, requiring manufacturers to carefully consider their target markets when formulating products.

2.3 The "LVP-VOC" Exemption

Some regulatory frameworks exempt low vapor pressure volatile organic compounds (LVP-VOCs) from VOC content calculations. LVP-VOCs are compounds with vapor pressure less than 0.1 mmHg at 20°C, which have minimal contribution to smog formation. Manufacturers may utilize LVP-VOC solvents and carriers to achieve lower reported VOC content while maintaining product performance.

2.4 Practical Implications for Formulators

Meeting VOC limits requires careful selection of solvents and carriers:

• Water-based formulations naturally achieve lower VOC content
• Bio-based solvents such as acetone glycerol (ACM) offer high flash points and low toxicity profiles
• LVP-VOC solvents can be used to reduce regulatory VOC content without compromising fragrance performance

3. Harmful Substance Limits: From Ingredient to Emissions

Recent regulatory developments have introduced comprehensive limits on harmful substances in fragrance products, with a particular focus on use-phase emissions.

3.1 Shanghai T/SEA 005-2025: Daily Fragrance Harmful Substance Limits

Effective March 2026, this groundbreaking Chinese group standard represents a paradigm shift in fragrance safety regulation. Developed by the Shanghai Indoor Environment Purification Industry Association, it is the first standard to address fragrance products from a use-phase emissions perspective.

Key Features of the Standard:

1. Scope Coverage: The standard applies to all daily-use fragrance products intended for public spaces, vehicles, and enclosed environments, including liquid, solid (non-combustible), and spray forms, covering both passive and active diffusion methods.

2. From "Ingredient Limits" to "Space Release Limits": Unlike traditional standards that focus on raw material composition, this standard requires that fragrance products, during actual use, must not emit volatile organic compounds, formaldehyde, or other pollutants exceeding national indoor air quality standards.

3. Core Pollutant Limits: The standard establishes strict release limits for:

4. Heavy Metal Limits: Referencing the 2015 Cosmetics Safety Technical Specification, the standard sets strict concentration limits for five heavy metals:

3.2 The Dynamic Testing Methodology

A key innovation in the Shanghai standard is its testing methodology. Rather than simply testing the product’s raw material composition, the standard employs a 1m³ environmental test chamber method. Under controlled conditions (23°C temperature, 50% humidity, specified airflow), the product’s actual emissions are measured over time, capturing both initial release and long-term behavior.

This dynamic approach revealed important findings. Research conducted during standard development found that products meeting all raw material ingredient limits could still exceed indoor air quality standards when tested in the environmental chamber. This demonstrates the critical importance of use-phase testing.

4. Material Restrictions: Prohibited and Restricted Substances

4.1 GB/T 22731 Fragrance (China)

The current national standard for fragrance raw materials restricts 125 chemical substances and prohibits 85 others. These restrictions apply to the raw materials used in fragrance formulation, covering:

• Sensitizing compounds
• Carcinogenic substances
• Reproductive toxins
• Persistent bioaccumulative toxins

4.2 IFRA Standards (International)

The International Fragrance Association (IFRA) maintains a comprehensive set of standards governing fragrance ingredient use. These standards are adopted by responsible manufacturers globally and include:

• Prohibited substances (e.g., certain nitromusks, polycyclic musks)
• Restricted substances with maximum use levels
• Specification limits based on application type

4.3 EU REACH and CLP Regulations

For products entering the European market, compliance with REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) is mandatory. REACH restricts substances of very high concern (SVHCs) and requires registration of all chemical substances above specified tonnage thresholds. CLP (Classification, Labeling, and Packaging) regulations govern hazard communication.

5. Antimicrobial and Food-Contact Applications

When scent sprays are used in public eating places, dairy-processing equipment, or food-processing facilities, additional regulatory requirements apply.

5.1 EPA Tolerance Exemptions

The U.S. Environmental Protection Agency has established exemptions from tolerance requirements for various fragrance components when used as inert ingredients in antimicrobial formulations applied to food-contact surfaces.

Key requirements for these exemptions:

These exemptions are based on the EPA’s determination that residues at these levels pose "no harm" to human health under the Federal Food, Drug, and Cosmetic Act (FFDCA).

5.2 FDA Food Contact Substance Notifications

For materials intended to contact food, manufacturers may need to comply with FDA Food Contact Substance (FCS) regulations. This applies when fragrance components are used in antimicrobial sprays applied to surfaces that later contact food.

6. Emerging Regulatory Trends

6.1 Expansion of VOC Regulations

Oregon is currently finalizing its own VOC regulations based on the OTC Model Rule—Phase V, with expected finalization by the end of 2025. This continues the trend of increasing state-level VOC controls.

6.2 Application-Based Classification

The Shanghai standard’s classification system—dividing products into passive diffusion (relying on natural evaporation) and active diffusion (using external energy like ultrasonic or heat)—represents an emerging approach that can adapt to rapid product innovation.

6.3 Third-Party Certification

Industry associations are increasingly implementing certification programs. The Shanghai Indoor Environment Purification Industry Association plans to conduct product evaluations and labeling for products that meet the T/SEA 005-2025 standard, helping consumers and commercial buyers identify compliant products.

7. Manufacturer Compliance Checklist

For B2B buyers sourcing public space scent sprays, the following checklist can help verify manufacturer compliance:

7.1 Raw Material Control

• All fragrance ingredients comply with GB/T 22731 or IFRA standards
• Prohibited substances list is maintained and enforced
• Restricted substances are within specified limits
• Suppliers provide Certificates of Analysis (COAs)

7.2 Formulation Compliance

• VOC content meets applicable federal and state limits (≤18% for pump sprays)
• Heavy metals meet limits per T/SEA 005-2025 or equivalent
• Formulation avoids prohibited phthalates and sensitizers

7.3 Emissions Testing

• Environmental chamber testing conducted per T/SEA 005-2025 methodology
• TVOC, formaldehyde, benzene series within limits
• PM2.5 emissions verified for active diffusion products

7.4 Labeling and Documentation

• Product labels include VOC content where required
• Safety Data Sheets (SDS) available
• Compliance declarations for target markets (China, US, EU)

Conclusion: A Commitment to Space Safety

Manufacturing scent sprays for public spaces demands a fundamentally different approach from household fragrances. The focus must shift from ingredient safety alone to space safety—ensuring that the product’s actual emissions in use do not compromise indoor air quality or occupant health.

At ENO Aroma, we recognize that public space applications carry heightened responsibility. Our formulations are developed with:

• VOC compliance across all target markets
• Use-phase emissions testing to verify indoor air quality safety
• Restricted substance controls aligned with global standards
• Heavy metal limits protecting against cumulative toxicity

For our B2B partners, this commitment means:

• Regulatory confidence: Products that meet the strictest standards for public space use
• Health protection: Formulations that safeguard building occupants and customers
• Market access: Compliance with emerging global regulatory frameworks
• Brand integrity: Assurance that safety claims are backed by verified test data

Interested in developing public space scent sprays that meet rigorous safety standards? Contact ENO Aroma to discuss our formulation capabilities and compliance testing services.